Privacy notice

Last updated: 23 August 2026

The German version is the legally binding version.

This notice applies to the website and web app. The native iOS app has an additional, dedicated app privacy notice.

1. Controller and privacy contact

The controller for CircleRecs is Axel Springer Deutschland GmbH, Axel-Springer-Straße 65, 10888 Berlin, Germany, telephone +49 30 2591 0. For product questions, contact support@circlerecs.com.

You can contact the data protection officer at Axel Springer Deutschland GmbH, Datenschutz, Axel-Springer-Straße 65, 10888 Berlin, or by email at datenschutz@axelspringer.com.

2. Website access and necessary browser storage

When you access the website and API, our hosting and security services process information such as your IP address, timestamp, requested URL, referrer, HTTP headers, browser and device information, response status, and error details. This is necessary to deliver the app, fix errors, and prevent misuse. The legal basis is Art. 6(1)(f) GDPR. Technical logs are generally deleted after 30 days.

On our own website, CircleRecs uses no advertising cookies and no third-party user tracking; for affiliate and booking links to partners and the redirect involved, see section 8. We only store information required for features you request: your language choice in a cookie for up to one year, sign-in and session information in session storage, your last selected circle in local storage, and a map position you choose to share in session storage. Access to this browser storage is based on Section 25(2) TDDDG. We do not show a cookie banner while we use only this necessary storage.

3. Waitlist, account, and social features

For the waitlist, we process your email address, language, signup source and time, delivery status, and waitlist status. We do this on the basis of your consent under Art. 6(1)(a) GDPR. You may withdraw it for the future at any time by contacting support@circlerecs.com.

When you sign in with Google or Apple, we receive the relevant account identifier and the basic information you release, such as email address, name, and profile image. In the app, we also process your profile and visibility settings, links you voluntarily add to your social profiles, circles, roles, invitations, chats, reactions, notification preferences, follows and blocks, recommendations, personal Want and Pass places, photos, Ask conversations, and reports. This is necessary to provide CircleRecs under Art. 6(1)(b) GDPR. We rely on Art. 6(1)(f) GDPR for security, misuse prevention, and technically necessary product improvement.

If you enable push notifications in the iOS app, we store a random installation identifier, the APNs device token issued by Apple, the development or production environment, bundle and app version, and optionally your language and time zone. We use this only to deliver and troubleshoot your Circle notifications. The app attempts to remove the registration when you sign out, and it is deleted with your account. Apple processes the data needed for delivery under its own terms.

CircleRecs is intended only for people aged 18 or older. You confirm the minimum age independently of the optional age field. If you provide your age, we derive and store your birth year for age-range filters you choose. Other users do not receive your exact birth year, but may receive a coarse age range derived from it. You can remove this information from your profile at any time; it is deleted no later than with your account. The legal basis is performance of the user contract under Art. 6(1)(b) GDPR.

Content in private circles is visible to their active members. If you make your profile public, your public profile, recommendations intended for that profile, and social-profile links you voluntarily add may also be visible outside your circles and without sign-in. For private profiles, signed-in users may still see the display name, username, profile photo, and aggregate counts; recommendations, places, bio, taste tags, social links, and the follower/following lists remain hidden. Private profiles are not shown in the ranked creator feed; signed-in users must explicitly enable the separate private-profile view and may then filter it by name or username. Following a private profile does not unlock this content. Profile owners can remove followers or block accounts. Private profile areas, private places, chats, blocks, and import previews are not displayed publicly.

If you join an Exclusive Circle through the iOS app, Apple independently processes the purchase and payment data. CircleRecs does not receive card or bank details. We process a random identifier linking the purchase to your app account, the Apple product identifier, original and latest transaction identifiers, sandbox or production environment, purchase and expiry times, and subscription, renewal, grace-period, refund, and revocation status. This is necessary to verify and restore the purchase, provide access, prevent duplicate assignment and misuse, and handle support, refunds, and reconciliation. The legal basis is Art. 6(1)(b) GDPR, Art. 6(1)(f) GDPR for misuse prevention and legal claims, and Art. 6(1)(c) GDPR for legally required accounting records.

For approved creators, we additionally process approval and account status, the assigned Apple product and Exclusive Circle, agreed revenue share, payout currency and threshold, and proceeds, refund, adjustment, and payout entries. Necessary contract, invoice, tax, and bank details are handled only through authorised finance and contracting processes and are not displayed publicly. The legal bases are Art. 6(1)(b) and (c) GDPR.

4. Location and voice input

The map requests your location only after you actively allow it in the browser or operating system. The position is used on your device to position the map. If you explicitly choose “Use location” in Discover creators, CircleRecs uses the current coordinate once to determine the city used by the creator filter. If you then use Ask for nearby recommendations, the visible map centre is processed with your question. We use this context only for the current request and do not store it as a location history. You can withdraw permission at any time in your browser or iOS settings, or move the map to a different area before using Ask.

The web app renders maps with the locally embedded open-source library MapLibre GL. It retrieves the map style and map tiles directly from OpenFreeMap. OpenFreeMap therefore receives technically necessary request data such as your IP address, browser and device information, and the requested map areas. For place searches, the Nominatim service on openstreetmap.org and, where needed, Geoapify may receive the search term, location context, language, and an optional country hint. Place data includes contributions from OpenStreetMap and the Overture Maps Foundation; queries and user data are not sent to Overture. The iOS app displays maps with Apple MapKit, uses it to offer address suggestions, and can open places in Apple Maps. Apple may process the technically necessary map and address-search requests, including the entered search term, and, if you grant location access, location data under its own privacy terms.

Voice input, for example in Ask or when writing a recommendation note, uses your browser's speech-recognition service or Apple Speech in the iOS app. The provider may process audio under its own terms; where the device supports it, the iOS app requests on-device recognition as well. If you enable additional audio processing, CircleRecs securely sends the short recording to OpenAI so names and places can be transcribed more reliably. Before the first processing, we ask for your consent under Art. 6(1)(a) GDPR. You may withdraw it for the future. CircleRecs does not retain the raw recording; temporary files are discarded after the request. The transcript and any content you save from it are processed like other product data. Voice is optional and you can always type instead.

5. AI and semantic search

OpenAI converts recommendation text and relevant location context into numerical representations called embeddings. Pinecone processes these representations and limited search metadata for semantic search. Depending on the scope you select, only your own content and circle, follow, or public content you are allowed to access is considered. CircleRecs continues to enforce the access rights that apply to each item.

Ask and AI-assisted place capture use an AI system. When you use these features, you are interacting with an AI system rather than a person. Answers and editable suggestions are created automatically from your input, recent conversation context where relevant, and matching sources, and are not editorially reviewed before you see them. The original recommendations remain visible as sources. When you add or import places, we may generate category and taste suggestions from publicly available place context (for example OpenStreetMap attributes); you can review and change them before saving. AI output may be incomplete or wrong. CircleRecs does not make decisions based solely on automated processing that produce legal or similarly significant effects for you.

If the detected language of a personal recommendation note visible to you differs from your selected app language, CircleRecs may use OpenAI to create a display translation. The original remains unchanged and can always be shown. Translations are refreshed when the original changes and deleted with the recommendation or account. They do not alter search, filters, Ask, or the editable original note.

When you start AI-assisted place search, the query, language, region, and the place or map context you selected may be sent to OpenAI. OpenAI may search publicly available web sources to suggest a venue identity, address, and—where reliably found on the official website of that exact venue—opening hours. CircleRecs does not accept AI-suggested coordinates without verification against our place catalogue and geocoding services. Suggestions may be wrong or outdated and can be reviewed before saving. Technical search hints may be cached for up to six hours to reduce repeated calls to external services.

We use OpenAI as a processor acting on our instructions solely to provide the CircleRecs features you request. The legal basis is Art. 6(1)(b) GDPR. Content processed through the API is not used for advertising or to train general-purpose AI models. A separate general AI consent toggle is therefore not required. The consent described in section 4 applies separately to transfer of a raw voice recording.

6. Google data

Google sign-in and Google Maps list import are separate features. List import starts only when you explicitly paste a public Google Maps list link. We then fetch the publicly available list data to show you editable place suggestions. The providers described in sections 5 and 9 may be used for this purpose. No Google sign-in is required for this import. You review and confirm what is saved before it is stored.

Import candidates remain private. Unselected candidates are not semantically indexed for circle search and are deleted no later than 30 days later. Only if you later publish a place as your own recommendation is your CircleRecs content processed as described in section 5. You can remove stored import data in the app, ask supportto remove it, or delete your CircleRecs account.

We use information from Google APIs and from public Google Maps lists you paste only for the sign-in and import features visible to you. We do not sell it, use it for advertising, or use it to train general-purpose AI models. Human access is allowed only when you explicitly request support, where needed for security, or where required by law. Where we use Google APIs, our use and transfer adheres to the Google API Services User Data Policy, including the Limited Use requirements.

Sharing of Google user data. We do not share, transfer, or disclose the data we receive through Google APIs or through a public list link you paste, including imported collections, places, links, and notes as well as Google sign-in data, to any third party, and we do not sell it, except: (a) to our service providers acting on our instructions solely to process, host, and secure this data on our behalf, namely Amazon Web Services (storage and database), Vercel (delivery of the web frontend), and OpenAI (category and tag suggestions you start); (b) when you explicitly consent to the sharing; (c) where strictly necessary to detect, prevent, or address security, fraud, or technical issues; or (d) where required by law or necessary to protect legal claims. We do not share this data with advertising, analytics, or data-broker services, and we do not use it to train general-purpose AI models. If you later explicitly publish an imported place as your own recommendation, the resulting CircleRecs content is processed as described in section 5.

Protection of your data, including sensitive data. Data is transmitted only over encrypted connections (TLS/HTTPS). Data at rest is stored on access-restricted infrastructure with encryption at rest. Access to Google user data is limited to legitimate purposes on a least-privilege basis and is controlled and logged. Import candidates remain private until you explicitly publish them. You can remove import data in the import area of the app, ask support to remove it, or delete your CircleRecs account.

7. Import from public social-media links

Through the iOS share sheet, you can send CircleRecs a public Instagram, TikTok, or YouTube post. We may process the public link, platform, text or caption supplied by the share sheet, and publicly available preview data (title, creator name, cover) to suggest a place. CircleRecs does not sign in to your social-media account or access private content.

We reduce link parameters to the required public post address. Shared text may be sent to OpenAI to prepare editable place suggestions. A caption does not automatically become your personal recommendation. Temporary share-extension files are removed after handoff or discard. Only places and media you confirm are stored with the visibility you choose. If you confirm the post is yours and choose to show it on the recommendation, we store the public link and the creator name you confirmed; the cover may then be stored as your recommendation photo. We do not store another creator's name or image as yours. Share only content you are entitled to use.

8. Affiliate and booking links

Some recommendations may contain booking links to partners, for example GetYourGuide. These links are advertising: if you complete a booking through them, Axel Springer Deutschland GmbH may receive a commission. This does not create any additional cost for you. We label such links accordingly in the app.

When you open such a link, CircleRecs may add a pseudonymous attribution code to the destination. We use this code only internally to attribute a resulting booking to the recommendation and circle that prompted it and to award community points. The code does not contain clear names readable by third parties. The legal basis is our legitimate interest in funding and gamifying the service under Art. 6(1)(f) GDPR.

After the click you leave CircleRecs and are on the partner's website. The partner is independently responsible for the processing that takes place there and may set its own cookies and process data under its own privacy policy. We do not set our own advertising or tracking cookies in your browser for these purposes.

To improve activation, reliability, and retention, CircleRecs processes limited, account-linked first-party product data. This includes no more than one active-day record per platform, the app version, and categorised actions such as opening a place detail, push notification, or Ask source, or sharing an invitation. These events contain no search text, message content, location coordinates, or place, recommendation, or Circle identifiers. The legal basis is our legitimate interest in developing a useful and stable service under Art. 6(1)(f) GDPR. We use no analytics cookies, analytics local storage, cross-app advertising tracking, or third-party analytics SDK for this purpose. You may object on grounds relating to your particular situation.

9. Recipients and transfers

Depending on your visibility settings, other circle members, followers, or internet users receive access to content intended for them. Our technical providers are Amazon Web Services for sign-in, databases, storage, live features, email, and logs; Vercel for the web frontend; Google for sign-in and for the public Google Maps list import you start; Apple for sign-in, App Store purchases and subscription status, MapKit and Apple Maps, native speech recognition, and push delivery; OpenFreeMap for map styles and tiles; the Nominatim service on openstreetmap.org and Geoapify for place searches and matching; OpenAI for AI, embeddings, transcription, and place classification; Pinecone for semantic search; Dash0 for technical observability; and Hostinger for the support mailbox. MapLibre GL runs as a local software library and does not itself receive user data. Place data from the Overture Maps Foundation is imported into our own catalogue; search queries are not sent to Overture. OpenAI is also used for the web search for public place information that you start. We may disclose data to authorities or other bodies where legally required or necessary to protect legal claims.

Where creators participate in the payout programme, only authorised product, legal, tax, and finance teams within the Axel Springer organisation receive the information needed for that purpose. Banks and, where legally required, tax authorities may receive payout data. Apple acts independently under its own privacy terms when processing App Store purchases.

Some providers may process data outside the European Economic Area. Where a third-country transfer occurs, we rely, depending on the recipient, on an adequacy decision, including the EU-US Data Privacy Framework for certified recipients, or appropriate safeguards under Art. 46 GDPR, in particular EU Standard Contractual Clauses and any necessary supplementary measures. You can obtain information about the safeguards used from the data protection officer.

10. Retention and deletion

We delete waitlist entries when you withdraw or no later than 12 months after signup unless you accept an invitation and create an account. Browser data ends with the session or the storage period stated above. Technical logs are generally retained for 30 days. Database backups expire after seven days unless longer retention is legally required.

Product analytics events and unselected Google import candidates are deleted no later than 30 days later. Cohort statistics derived from them contain no user or content identifier and remain only as aggregate metrics. Technical AI place-search hints may be cached for up to six hours. Temporary social-share files are removed after handoff or discard. Affiliate attribution is deleted no later than 90 days later. Raw voice recordings are processed only for the relevant transcription request and then discarded.

Product data remains stored while your account is active or while required for the service, misuse prevention, legal defence, or legal obligations. You can delete individual content and your account in the app. Account deletion removes associated active product data, media, Google import data, and semantic search documents; remaining backup copies expire according to the backup schedule. We retain reports and moderation communication only as long as necessary for review, legal defence, and legal obligations.

Deleting your CircleRecs account does not cancel an Apple subscription. We delete or detach the active account association, while minimised transaction and payout records may be kept for Apple notifications, refunds, misuse prevention, legal claims, and statutory accounting and retention duties. They are deleted or anonymised when those purposes end. You can manage and cancel the subscription separately in your Apple Account.

11. Avoid unnecessary sensitive data

Please do not enter unnecessary sensitive data in free text or voice input, or upload confidential information about other people in photos or videos. Before sharing, check that people shown or mentioned agree and that you are allowed to use the content.

12. Your data protection rights

Subject to the legal requirements, you have, in particular, the right to access, rectification, erasure, restriction of processing, data portability and objection, as well as the right to withdraw consent with effect for the future. To exercise your rights, contact datenschutz@axelspringer.com and use “CircleRecs – Betroffenenrechte” as the subject. You also have the right to lodge a complaint with a data protection supervisory authority.

The competent authority is, in particular, the Berlin Commissioner for Data Protection and Freedom of Information, Alt-Moabit 59-61, 10555 Berlin, email mailbox@datenschutz-berlin.de.

You are not legally required to provide data. Without an email address, we cannot add you to the waitlist; without a supported Apple or Google account, we cannot create a CircleRecs account; and without confirming the minimum age, we cannot provide the service. We require a display name for your profile. Your age, profile image, and all other profile, place, and content information are optional.